Worldwide: Transfer Pricing

Delaware Statutory Trusts (DSTs) continue to grow in popularity as a passive real estate investment vehicle — especially for investors seeking a streamlined option in a 1031 exchange.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

On January 5, 2026, the OECD Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) released the highly anticipated Side-by-Side (SbS) package.

The Global Tax Policy and Controversy (TPC) Group at A&M Tax is pleased to bring you this month's edition of our newsletter, A&M Tax Policy Insights.

While most transfer pricing rules will apply to large multinational enterprise (MNE) groups, family offices, foundations, and trusts cannot ignore them.

As companies finalize their Q2 2025 reporting, tax departments are once again navigating a shifting landscape of legislative and regulatory change. The centerpiece of this quarter's developments was the advancement...

Our recent blog post, The First Sale Doctrine: A Strategic Tool for Reducing Tariffs—But Only If You Do It Right, generated a lot of questions.

President Trump has signed into law a comprehensive tax reform package that permanently extends several expiring provisions of the Tax Cuts and Jobs Act (TCJA) and enacts key tax measures central to his 2024 reelection...